Loading...
HomeMy WebLinkAboutNCS000460_(Signed) MS4 Audit_20231009 MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PROGRAM AUDIT REPORT NPDES PERMIT NO. NCS000460 Town of Knightdale, NORTH CAROLINA 950 Steeple Square Ct, Knightdale, NC 27545 Audit Date: 08/23/2023 Report Date: 10/09/2023 North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 9th floor 1612 Mail Service Center Raleigh, NC 27699-1612 TABLE OF CONTENTS AuditDetails_...... ....................................................................................................................................... 1 PermitteeInformation.................................................................................................................................. Listof Supporting Documents............................................................................................................I......... 3 Program Implementation, Documenkatiun & Assessment.......................................................................... 4 Public Education and Outreach.............................. ................... ...... .................................................. ... S Public Involvement and Participation ............................................................Error!Bookmark not defined. Illicit Discharge Detec#ion and Elimination (IDDE)..................................................................................... 11 Construction Site Runoff Controls..................................................................Error! BookrnaA not defined. Post-ConstruKtion Site Runoff Controls..........................................................Error! Bookmark not defined. Pollution Prevention and Wod Housekeeping for Municipal Operations............................................. ... 15 Total Maximum Daily Loads(TMfts}.... .. . . . . . ....... .. .. . . .. ..Error! Bookmark not defined. Site Visit Evaluation* Municipal Facility No. 1 ............................................................................................ 1 Site Visit Evaluation; Municipal Facility No.2 ... ... ..... ..... . ..... ..... ..... .....Errorl Bookmark not defi ned. Site Visit Evaluation: MS4 Outfali No. 1 ..................................................................................................... 20 Site Visit Evaluation, M54 0utfa11 No. 2 ........................... .............................Errort Bookmark not defi ned. Site Visit Evaluation: Construction Site fro. 1.................................................Errort Bookmark not defined. Site Visit Evaluation: Construction Site No. 2.................................................Erroet Bookmark not defined. Site Visit Evaluation. Post-Construction Starm water Control Measure No. 1........................................... 22 Site Visit Evaluation: post-Construction Stormwater Control Measure No.2Errorl Bookmark not deftried. Appendix A.Supporting Documents Appendix B' Photograph frog DISCLAIMER This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This audit report does not include a review of all program components, and program deficiencies in addition to those noted may be present. The permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. NCS000485 Nashville MS4 Audit 20230719 5 This page intentionally left blank NCS000485 Nashville M54 Audit 20230719 III Audit Details Audit ID Number: Audit Date(s): NC5000460—Knightdale MS4 Audit_20230823 08/23/2023 Minimum Control Measures Evaluated: ® Program Implementation, Documentation&Assessment ® Public Education &Outreach ❑ Public Involvement&Participation ® Illicit Discharge Detection&Elimination ❑ Construction Site Runoff Controls—No delegated Sediment and Erosion Control Program ❑ Construction Site Runoff Controls—Delegated Sediment and Erosion Control Program ❑ Post-Construction Site Runoff Controls ® Pollution Prevention and Good Housekeeping for Municipal Operations ❑ Total Maximum Daily Loads(TMDLs) Field Site Visits: ® Municipal Facilities. Number visited: 1 ® MS4 Outfalls. Number visited: 1 ❑ Construction Sites. Number visited:Choose an item. ® Post-Construction Stormwater Runoff Controls. Number visited: 1 ❑ Other: Number visited:Choose an item. ❑ Other: Number visited:Choose an item. Inspector(s)Conducting Audit Name.Title Organization Thad Valentine—Senior Environmental Specialist NCDEQ Celina Amaya—Senior Environmental Specialist NCDEQ Audit Report Author: Date: Signature l l// � �� V 9 Audit Report Au hor: y Date q Signature I D l ! /L a ■.rn ­r:. -PC Permittee Information MS4 Permittee Name: Permit Effective pate: Permit Expiration Date: Town of Knightdale Mailing Address: Date of Last MS4 Inspection/Audit: 950 Steeple Square Ct, Knightdale, NC 27545 Co-permittee(s),if applicable: Permit Owner of Record: Primary MS4 Representatives Participating in Audit Name,Title Organization Dustin Tripp—Assistant Town Manager(OP) Town of Knightdale Phillip Bunton-Public Works Director Town of Knightdale Ike Archer—Stormwater Program Manager Town of Knightdale Dylan Kirk—Stormwater Technician Town of Knightdale Domingo Orpilla- Town of Knightdale John Stover- MS4 Receiving Waters Waterbodv Classification Impairments NCS000460_Knightdale MS4 Audit_20190823 Page 2 of 25 List of Supporting Documents Item Document Title When Provided Number (Prior to/During/After) 1 Town Position Organizational Chart 2 Town Chart of Responsibilities 3 2022 Annual Report 4 SWMP 4 CWEP Agreement 5 Foater Lake& Pond Management Inc(SCM) Management 6 G2 Design(SCM) Management 7 Incident Report 8 M54 O&M Plan NCS000460_Knightdale MS4 Audit_20190823 Page 3 of 23 Program Implementation, Documentation & Assessment Staff Interviewed: Ike Archer—Town of Knightdale,Stormwater Manager (Name,Title,Role) Dylan Kirk—Town of Knightdale,Stormwater Technician Permit Citation Program Requirement Status Supporting Doc No. II.A.1 The permittee maintained adequate funding and staffing to implement and manage Staffing and Partial --- the provisions of the Stormwater Plan and meet all requirements of the permit. Funding The Stormwater Plan identifies a specific position(s)responsible for the overall Yes 1 coordination,implementation, and revision to the Plan. Responsibilities for all components of the Stormwater Plan are documented and Yes 2 position(s)assignments provided. The permittee is current on payment of invoiced administering and compliance Yes --- monitoring fees(see Stormwater a payments on DEMCR MS4 web page). Comments Funded fully by the stormwater fee which is$6.75 per Equivalent Residential unit(ERU). Fiscal Year 2024:Total 1.6 million allocated(see breakdown below). $713,000 dedicated to administration. $365,000 dedicated to implementation. $600,000 dedicated to CIP. The Town of Knightdale believes the funding that is currently allocated is adequate to supply the needs of the stormwater program. Two positions fully dedicated to stormwater(Stormwater Manager and the Stormwater Technician). 1.5 positions partially dedicated to stormwater(see org chart and Table 8 Summary of Responsible parties). Thad: Ensure all staff(including Dylan Kirk)are included on the Table 8:Summary of Responsible Parties. II.A.2 Stormwater The permittee evaluated the performance and effectiveness of the program Plan Yes 3 components at least annually. Implementation and Evaluation If yes,the permittee used the results of the evaluation to modify the program No components as necessary to accomplish the intent of the Stormwater Program. Did the permitted MS4 discharges cause or contribute to non-attainment of an No applicable water quality standard? If yes,did the permittee expand or better tailor its BMPs accordingly to address Not the non-attainment? Applicable --- NCS000460_Knightdale MS4 Audit_20190823 Page 4 of 23 Program Implementation, Documentation &Assessment Comments The Town of Knightdale indicated they use the annual reports for their yearly self-evaluation to improve the program, but adequate documentation is currently not provided and needs to be improved upon. Town of Knightdale must properly document their own internal evaluation/audit after submitting the annual BIMS report.This document should evaluate where the Town is with the program and specify how they plan to improve the program highlighting all parts of the program that the annual report states, has not been fully implemented.This evaluation should include current projections for the implementation of any portions of the program that are not properly funded or staffed as indicated on the annual report II.A.3 Keeping the The permittee kept the Stormwater Plan up to date. Yes 4 Stormwater Plan Up to Date The permittee notified DEMLR of any updates to the Stormwater Plan. No --- Comments The annual reports are available on the Town of Knightdale Stormwater webpage(up to the current 2022 report). II.A.4 Availability The permittee kept an up-to-date version of its Stormwater Plan available to the Yes Town of the Stormwater Division and the public online. Website Plan The online materials included ordinances,or other regulatory mechanisms, or a list identifying the ordinances,or other regulatory mechanisms, providing the legal Yes Town Website authority necessary to implement and enforce the requirements of the permit. Comments The SWMP is available on the Town of Knightdale webpage for public viewing. All ordinances are available on the Town of Knightdale webpage for public viewing including the ordinance that provides the legal authority necessary to implement and enforce the requirements of the program(Chapter 9.4 Stormwater Management:Section A.3 Authority). II.A.3&II.A.S Stormwater Plan Did DEMLR require a modification to the Stormwater Plan? No --- Modifications If yes,did the permittee complete the modifications in accordance with the Not established deadline? Applicable --- Comments Prior to 2020,Wake County conducted routine inspections.Since then the Town of Knightdale has local jurisdiction for the sediment and erosion control program . II.A.6 Sharing Responsibility Are any control measures implemented by an entity other than the permittee? Yes --- If yes,is there a written agreement in place? Yes 5,6&7 Comments The Town has agreements with G2 Design&Foster Lake and Pond far SCM maintenance and with the Clean Water Education Partnership(CWEP)for public education& Outreach and Public involvement and Participation NCS000460 Knightdale MS4 Audit.20190823 Page 5 of 23 Program Implementation, Documentation &Assessment II.A.7 The permittee maintained written procedures for implementing the six minimum Written control measures. Yes Procedures Written procedures identified specific action steps,schedules,resources and Yes responsibilities for implementing the six minimum measures. Comments Written procedures for the(6)minimum measures were reviewed and adequate.We would recommend including who is responsible for the implementation of the program within the Illicit Discharge Detection and Elimination Program(IDDE).Although other supplementary documents include the responsible parties, it is recommended that the responsible parties be included throughout the document for clarity. Ill.A The permittee-maintained documentation of all program components including,but Program not limited to, inspections,maintenance activities, educational programs, Yes Documentation implementation of BMPs, enforcement actions etc.,on file for a period of five years. Comments The Town uses CBI Systems software(MS4Web)which includes facilities, outfalls,SCMS and records all investigations and inspections.The example complaint that was reviewed showed it was received and logged into the system that was followed by the investigation process,documentation,and remediation.The report documentation was thorough and includes photos,pertinent information,remediation details,recission letter,and contact information.There is also an excel spreadsheet that documents all of the inspections and the results.The Town of Knightdale staff believe the program is working very effectively. 111.E The permittee submitted annual reports to the Department within twelve months Annual Report from the effective date of the permit(See Section 111.B.for the annual reporting Yes Submittal period specific to this MS4). The permittee submitted subsequent annual reports every twelve months from the Yes scheduled date of the first annual report submittal. The Annual Reports included appropriate information to accurately describe the progress,status,and results of the permittee's Stormwater Plan, including,but not limited the following: 1. A detailed description of the status of implementation of the Stormwater Plan as a whole.This will include information on development and implementation Partial of each major component of the Stormwater Plan for the past year and schedules and plans for the year following each report. 2. An adequate description and justification of any proposed changes to the Stormwater Plan.This will include descriptions and supporting information for Partial the proposed changes and how these changes will impact the Stormwater Plan(results,effectiveness,implementation schedule,etc.). 3. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Partial Plan. 4. A summary of data accumulated as part of the Stormwater Plan throughout the year along with an assessment of what the data indicates in light of the Partial Stormwater Plan. 5. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities,inspections,and enforcement Yes actions. NCS000460 Knightdale MS4 Audit_20190523 Page 6 of 23 Program Implementation, Documentation & Assessment Comments Target pollutants and audiences should be identified in the SWMP and a follow up with the proposed changes and implementation in the Annual report IV.B Annual Reporting The Annual Reports document the following: 1. A summary of past year activities, including where applicable,specific Yes quantities achieved and summaries of enforcement actions. 2. A description of the effectiveness of each program component. No 3. Planned activities and changes for the next reporting period,for each Partial program component or activity. 4. Fiscal analysis. Partial Comments The effectiveness of each program should be summarized for future improvements for each program and any parts of a program in the annual report that state future development should be more specific with timelines listed in annual reports Additional Comments: Any components of the program that have been listed as not fully implemented in that annual report should be the focus of the yearly self-evaluation with detailed recommendations and time projections too fully comply with all those elements NCS000460_Knightdale MS4 Audit_20190823 Page 7 of 23 Public Education and Outreach Staff Interviewed. Ike Archer—Town of Knightdale,Stormwater Manager (Name,Title,Role) Dylan Kirk—Town of Knightdale,Stormwater Technician Permit Citation Program Requirement Status supporting Doc No. II.B.2.a The permittee defined goals and objectives of the Local Public Education and Goals and Yes Objectives Outreach Program based on community wide issues. Comments The goals are defined and listed in the Education and outreach Plan.The overall goals are defined followed by the methods,target pollutants,and target audiences. II.B.2.b The permittee maintained a description of the target pollutants and/or stressors and Yes Target Pollutants likely sources. Comments The following pollutants and likely sources are listed in the Town of Knightdale Public Education and Outreach document(internal only): Copper and PCB's—Industrial, Municipal Staff Mercury Statewide TMDL—Atmospheric Deposition Nitrogen Neuse TMDL—Failing septic systems,urbanization,residential,commercial,schools. Feval Coliform—Residential,Commercial,schools Litter—Residential,Commercial,schools Nutrients—Fertilizer/pesticides,failing septic systems, urbanization, residential,commercial,schools. Sediment-Industrial, Municipal,Construction Yard Waste-Residential,Commercial, municipal staff None noted as missing or inappropriate. II.8.2.c The permittee identified,assessed annually and updated the description of the target Partial - Target Audiences audiences likely to have significant storm water impacts and why they were selected. NCS000460_Knightdale MS4 Audit_20190823 Page 8 of 23 Public Education and Outreach Comments Focusing on target audiences and mode of distribution of educational material is a priority for this program in the future.Work on identifying which communities(Residential, Business& Industry)have pollutants that are most critical to improving water quality and community health and identify which mode of educational material would be best served to inform the community of those concerns. II.B.2.d Residential The permittee described issues, such as pollutants,the likely sources of those and Industrial/ pollutants,potential impacts,and the physical attributes of stormwater runoff in Yes Commercial Issues their education/outreach program. Comments The information is publicly available on the website and explicitly stated in internal documents.There is an internal record for every public outreach event with pertinent information including number of attendees,number of materials distributed,partners,and topics covered with the public. II.13.2.e The permittee promoted and maintained an internet web site designed to convey the Informational Yes Web Site program's message. Comments There is a TOK Stormwater webpage,and a specific page dedicated to education and outreach.This clearly conveys the programs message and educational information to the public to access as needed. ILB.2.f The permittee distributed stormwater educational material to appropriate target Public Education Yes Materials groups. Comments The TOK provides guidance for specific commercial facilities with targeted information related to stormwater and illicit discharge concerning that specific business. Educational pamphlets from CWEP and refrigerator magnets produced by the TOK with the stormwater hotline are provided at an informational booth that is run by the TOK. UNC and CWEP produced a poster for common pollutants targeted to restaurants that are provided online to be posted in restaurants for training purposes. NCS000460_Knightdale MS4 Audit.20190823 Page 9 of 23 Public Education and Outreach II.8.2.g The permittee promoted and maintained a stormwater hotline/helpline for the Town Hotline/Help Line purpose of public education and outreach. Yes Website Comments There is an online form that is filled out to report a problem. If there are erosion control or stormwater complaints,they are immediately sent to the appropriate stormwater staff so they can be investigated as soon as possible.The TOK Stormwater Program's internal goal is to investigate these complaints within 24 hours. It is recommended that the IICO explicitly state the goal timeframes for responding and addressing complaints for clear reference. 11.8'2.h The permittee's outreach program, including those elements implemented locally or Public Education through a cooperative agreement, included a combination of approaches designed to Yes --- and Outreach reach the target audiences. Program For each media,event or activity,including those elements implemented locally or through a cooperative agreement the permittee estimated and recorded the extent Yes --- of exposure. Comments There is an internal record for every public outreach event with pertinent information including number of attendees, number of materials distributed,partners,and topics covered with the public. Engagement metrics for the annual Creek Week event are recorded in Appendix 8 of the Public Education and Outreach section of the internal TOK document Additional Comments: CWEP provides much of the needed educational materials and with that and other,self-developed materials and resources,the town should focus on how best to distribute those resources to the different communities (Residential,industry&Business). NCS000460_Knightdale MS4 Audit_20190823 Page 10 of 23 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Ike Archer—Town of Knightdale,Stormwater Manager (Name,Title, Dylan Kirk—Town of Knightdale,Stormwater Technician Role) Permit Citation Program Requirement Status Supporting Doc No. II.D.2.a IDDE Program The permittee maintained a written IDDE Program. Ye.. If yes,the written program includes provisions for program assessment and evaluation and integrating program. Comments IDOE Program Summary of Key Components includes Section 4: Evaluate and assess the IDDE Program.This section includes a yearly audit to evaluate the IDDE program. Provide an internal program assessment,separate from the BIMS annual report,to evaluate and implement all components of the Illicit Discharge program in a standalone document. The permittee maintained an IDDE ordinance or other regulatory mechanism(s)that Yes II.D.2.b provides the legal authority to prohibit illicit connections and discharges to the MS4. Legal Authorities If yes,the ordinance applies throughout the corporate limits of the permittee. Yes [Permit Part 1.D] Comments This document exists within the overall UDO which covers all planning jurisdictions including corporate and ETJ limits. II.D.2.c The permittee maintained a current map showing major outfalls* and receiving Storm Sewer Yes System Map streams. Comments GIS mapping was first conducted in 2017 and a GIS intern contributed to the data entry for the stormwater GIS.All the stormwater inlets,piping,and major outfalls are mapped in ArcGIS for reference during inspections and planning(corporate limits only—not ETJ).All major outfalls were confirmed to meet the size requirements.Any areas that are missing data or new development are added when as-builts are received. Provide an internal annual assessment,separate from the BIMS annual report, to evaluate and implement all components of the Illicit Discharge program in a standalone document. *Major outfalls are discharges from>36"diameter pipes or drainage areas of:?50 acres. in areas zoned for industrial activity,major outfalls are>12"or drainage area>2 acres. NCS000460_Knightdale MS4 Audit 20190823 Page 11 of 23 Illicit Discharge Detection and Elimination (IDDE) II.D.2.d IDDE Dry Weather Flow The permittee maintained a program for conducting dry weather flow field Yes General observations in accordance with written procedures. Pfogram Program Supplement Comments Page 12 of the IDDE General Program Supplement details spill response follow up activities.The Town of Knightdale staff also use Chapter 7 of the EPA Guidance Technical Assessment Manual as a frequent reference for conducting the investigation. 100E General II.D.2.e Program Investigation The permittee maintained written procedures for conducting investigations of Part a Supplement identified illicit discharges. and EPa16UE Procedures Guidance Manual Comments Page 12 of the IDDE General Program Supplement details spill response follow up activities.These procedures include: Issuing a Notice of Violation Schedule a site re-visit to determine is corrective actions are complete. Contact the responsible party frequently and indicate contact events in the complaint file. Contact supporting agencies frequently and indicate contact events in the complaint file. - Schedule inspections through other programs for monitoring purposes. Coordinate with state agencies outside of the Town's MS4 authority. Provide mailings to problem areas. Develop a long-term monitoring program. Sent a letter to file summarizing the findings. The Town of Knightdale staff also use Chapter 7 of the EPA IDDE Guidance Technical Assessment Manual as a frequent reference for conducting the investigation.While the EPA document is a helpful reference,it appears to be too general.We recommend that written procedures for an illicit discharge investigation be included in TOK documents for staff to reference as standard operating procedures. II.D.2.f For each case of an illicit discharge or potential illicit discharge,the permittee documented and tracked the Track and following: Document Investigations 1. The date(s)the illicit discharge was observed Yes 2. The results of the investigation Yes 3. Any follow-up of the investigation Yes 4. The date the investigation was closed Yes Comments A standardized inspection report is generated using the MS4Web that includes all the required information. NCS000460_Knightdale MS4 Audit_20190823 Page 12 of 23 Illicit Discharge Detection and Elimination (IDDE) II.D.2.g Employee The permittee implemented and documented a training program for appropriate Training municipal staff who,as part of their normal job responsibilities, may come into Yes contact with or otherwise observe an illicit discharge or illicit connection. Comments They are working to implement online training to assign training annually for staff to complete. New staff are trained and audited to ensure they are following the standard operating procedures.Storm Watch program is used for training.Currently,the training is conducted as often as possible,but with the online form of training,they hope to target the training to all relevant staff annually. All training modules and sign in sheets are documented on the Town's SharePoint and the information will be used to generate a report. II.D.2.h The permittee informed public employees of hazards associated with illegal Public Education discharges and improper disposal of waste. Yes The permittee informed businesses of hazards associated with illegal discharges and Yes improper disposal of waste. The permittee informed the general public of hazards associated with illegal Yes discharges and improper disposal of waste. Comments The TOK provides targeted educational materials to the appropriate parties and guidance through inspection reports and Notices of Violations.The documents are not currently available to the public online but that is a goal for the TOK. II.D.2.1 The permittee promoted,publicized,and facilitated a reporting mechanism for the Public Reporting Yes public to report illicit discharges. Mechanism The permittee promoted,publicized,and facilitated a reporting mechanism for staff Yes to report illicit discharges. The permittee established and implemented response procedures for citizen Partial requests/reports. Comments Pamphlets, posters, refrigerator magnets that are distributed at events.Additionally,the TOK website has all of the educational material available and social media posts.Targeted mail handouts are sent to residents regarding how to avoid causing illicit discharges and report illicit discharges.The hotline number used to be displayed on the town trucks and it available on all educational materials both online and physical. There is an option when reporting illicit discharges,they can contact the hotline and the public works email.There is a section where the report is marked indicating that it was submitted by staff members. There is an SOP for responding to hotline complaints and the internal goal is to respond within 24 hours and on average they are inspected within one hour of being received.There is a tracking spreadsheet for recording the receipt and response to all hotline reports(IDDE Program Document). NCS000460 Knightdale MS4 Audit.20190823 Page 13 of 23 Illicit Discharge Detection and Elimination (IDDE) II.D.2.1 The permittee implemented a mechanism to track the issuance of notices of violation Enforcement Yes 7 and enforcement actions administered by the permittee. If yes,the mechanism includes the ability to identify chronic violators for Yes --- initiation of actions to reduce noncompliance. Comments The Town maintains a incident Hotline and there is a tracking spreadsheet on the Town's SharePoint for all IDDE investigations which includes: Violator name Tracking ID NOV/Enforcement date - NOV/Enforcement Action Summary Previous Violator(Y/N) Location of Documentation Additional Comments: A process for reporting illicit discharges should be developed to outline the step-by-step procedures for reporting illicit discharges.The sequence for reporting should be established not only for Town employees, but for citizens and businesses and should include step-by-step method of reporting, recording,maintaining, and sharing information with the general public NCS000460 Knightdale MS4 Audit 20190823 Page 14 of 23 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Ilse Archer—Town of Knightdale,Stormwater Manager (Name,Title, Role) Dylan Kirk—Town of Knightdale,Stormwater Technician Permit Citation Program Requirement Status Supporting Doc No. II.G.2.a The permittee maintained a current inventory of facilities and operations owned Facility Inventory and operated by the permittee with the potential for generating polluted Yes stormwater runoff. Comments Town owned and maintained facilities are tracked on a municipal facilities inventory, in addition to a map in MS4Web that tracks all investigations. II.G.2.b The permittee maintained and implemented an O&M program for municipally Operation and owned and operated facilities with the potential for generating polluted Partial Maintenance(O&M) stormwater runoff. for Facilities If yes,the O&M program specifies the frequency of inspections. No if yes,the 0&M program specifies the frequency of routine maintenance No requirements. if yes,the permittee evaluated the O&M program annually and updated it as No necessary. Comments The Town maintains a general O&M plan for municipally owned facilities.This O&M plan does not provide site specific O&M guidance for each facility and the 0&M plans are not kept at each facility for that specific facility. The frequency of inspections is currently on a "as needed"basis and after any spill or incident is reported. II.G.2.c Spill Response The permittee had written spill response procedures for municipal operations. Partiai Procedures Comments All staff are trained annually for spill response.Spill response procedures were not available at each municipality II.G.2.d Streets, The permittee evaluated existing and new BMPs that reduce polluted stormwater Roads,and Public runoff from municipally-owned streets,roads,and public parking lots within its Yes Parking Lots corporate limits annually. Maintenance If yes,the permittee evaluated the effectiveness of existing and new BMPs Yes based on cost and the estimated quantity of pollutants removed. NCS000460 Knightdale MS4 Audit.20190823 Page 15 of 23 Pollution Prevention and Good Housekeeping for Municipal Operations Comments The Town is funded and staffed well enough to have sufficient time and resources to provide for street maintenance that doesn't require an evaluation of 8MP's. Leaf pickup begins in November and continues through February with every street being swept each month.Additional sweeping is conducted after special town events and if a resident complaint is received,additional sweeping is performed in those cases. II.G.2.f The permittee maintained and implemented an O&M program for the stormwater O&M for Catch sewer system including catch basins and conveyance systems that it owns and Yes 8 Basins and maintains. Conveyance Systems Comments The document provided "Municipal Separate Storm Sewer(MS4)Operation and Maintenance Plan"outlines storm drain cleaning, street sweeping,inspections,and storm drainage outfall maintenance. II.G.2.g The permittee maintained a current inventory of municipally-owned or operated Structural structural stormwater controls installed for compliance with the permittee's post- Yes --- Stormwater Controls construction ordinance. Comments Nine municipally owned SCMs are tracked on a spreadsheet provided in the"Municipal Owned Stormwater Control Measures Operation and Maintenance Plan".All SCM facilities are mapped in GIS and the Town's CBI Inspection Software.This database is updated as new SCMs are certified and brought online. II.G.2.1h The permittee maintained and implemented an 0&M program for municipally- O&M for Structural owned or maintained structural stormwater controls installed for compliance with Yes Stormwater Controls the permittee's post-construction ordinance. If yes,then: The O&M program specified the frequency of inspections and routine Yes --- maintenance requirements. The permittee documented inspections of all municipally-owned or maintained Yes --_ structural Stormwater controls. The permittee inspected all municipally-owned or maintained structural Yes --- stormwater controls in accordance with the schedule developed by permittee. The permittee maintained all municipally-owned or maintained structural Yes --- stormwater controls in accordance with the schedule developed by permittee. The permittee documented maintenance of all municipally-owned or Yes --- maintained structural stormwater controls. Comments Maintenance is conducted as needed when observed during monthly routine inspections(conducted by Foster Lake and Pond Management).The annual inspection is conducted by a third-party inspector II.G.2.1 The permittee ensured municipal employees are properly trained in pesticide, --- herbicide and fertilizer application management. Yes NC5000460_Knightdale MS4 Audit_20190823 Page 16 of 23 Pollution Prevention and Good Housekeeping for Municipal Operations Pesticide, Herbicide The permittee ensured contractors are property trained in pesticide,herbicide and and Fertilizer fertilizer application management. Yes Application Management The permittee ensured all permits,certifications,and other measures for applicators are followed. Comments Contractors that apply herbicide and pesticides are licensed as required by their contract.Their licensing numbers are included in the submitted reports. Expiration dates are verified and kept up to date.Town employees are certified and are updated as they near expiration.All proposed work goes through an approval process and monthly reports are reviewed II.G.2.i The permittee implemented an employee training program for employees involved Staff Training *� in implementing pollution prevention and good housekeeping practices. Comments All operations and grounds maintenance staff are trained annually in pollution prevention and good housekeeping. II.G.2.1k The permittee described and implemented measures that prevent or minimize Vehicle and contamination of stormwater runoff from all areas used for vehicle and equipment Yes Equipment Cleaning cleaning. Comments All fleet vehicles are washed at a commercial facility that discharges to sanitary sewer.There are no town owned vehicle washing stations, but they have an SOP that states that all vehicle washing must be discharged into a sanitary sewer system and includes procedures for where to wash vehicles that are too large to fit in commercial car washes.There is a standard operating procedure for Vehicle and Equipment Washing under the Municipal Facilities Operation and Maintenance Plan,Section G. Additional Comments: The inspection frequency of Town municipalities should be established and provided for each of the municipal facility O&M plans. Each 0&M plan should provide a schedule of maintenance requirements expected to be accomplished in these inspections. (ex.oil leaks,Structurally Sound Containment with no cracks or leaking, vehicle/equipment wash bays"if applicable" maintained properly,oil water separator maintenance,etc...} Spill response procedures should be located at all municipal owned facilities Spill response procedures should be located at each municipal facility and should be posted in areas with a likelihood for spills,such as fueling stations,storage tanks transfer points. Municipally owned and operated SCM's should have a site specific O&M plan that includes items specific to that SCM to inspect.(ex.Type of SCM "Wet or Dry",Vegetation type both trees and grass,subsoil media type and inspection frequency, etc..). Each SCM is unique,with plantings and characteristics distinctive to the pollutant being controlled,therefore each SCM should have it's own O&M plan. NCS000460 Knightdale MS4 Audit.20190823 Page 17 of 23 Site Visit Evaluation: Municipal Facility No. 1 Facility Name: Date and Time of Site Visit: Public Works#1 August 23, 2023, 1:00 pm—2:10 pm Facility Address: Facility Type(Vehicle Maintenance,Landscaping,etc.): 1102 Great Falls Court Vehicle Maintenance and materials storage. Knightdale, NC 27545 Name of MS4 inspector(s)evaluated: Most Recent MS4 Inspection(List date and name of inspector): Ike Archer August 2, 2023 Name(s)and Title(s)of Facility Representative(s)Present During the Site Visit: Name Title Ike Archer Town of Knightdale,Stormwater Manager Dylan Kirk Town of Knightdale,Stormwater Technician Observations Facility Documentation/Training Does the facility have a Stormwater Pollution Prevention Plan(SWPPP)or similar document?Is it facility-specific? There is not a SWPPP document,there is an Operations and Maintenance plan that is referenced.The plan is not site specific. What type of stormwater training do facility employees receive?How often? Only spill prevention training is provided to the employees of this facility Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? North Carolina State University Stormwater SCM Inspection&Maintenance Certification. Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping? Yes. Did the MS4 inspector appear knowledgeable about Stormwater pollution prevention and good housekeeping? Yes. Inspection Procedures Does the MS4 inspector's process include the use of a checklist or other standardized form? Yes. Does the MS4 inspector's process include taking photos? Yes. Does the MS4 inspector's process include reviewing the facility's SWPPP(or similar document)? No.There is not a SWPPP on site, but there is an Operations and Maintenance plan that is referenced. NCS000460_Knightdale MS4 Audit_20190823 Page 18 of 23 Site Visit Evaluation: Municipal Facility No. 1 Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge? The inspector stated that the typical inspection was conducted outside and excluded areas thatwere indoors or under cover or in a containment area. Did the MS4 inspector miss any obvious areas of concern?If so,explain: The inspector stated that the typical inspection was conducted outside and excluded areas that were indoors or under coverage which misses several areas of concern.The inside areas were inspected once NCDEQ staff informed the inspector of those areas that were overlooked and will continue to be completed as required. Does the MS4 inspector's process include presenting the inspection findings to the facility contact? Yes,the inspector sends the inspection report and photos to the public works director for their review and to complete any corrective actions. Inspection Results Did the facility inspection result in any corrective actions to be implemented?If so,for what issue(s)? Yes, minor maintenance and clean up items were identified during the inspection including the following: - Spray paint cans stored in an open trailer with no cover. - Slope stabilization issues along the boundary of the parking lot which is causing slight sediment deposition. - One dumpster is missing a plug. - Unlabeled grease drum. - Minor debris and loose waste in the dumpster area. - Minor oil leaks from staff and fleet vehicles onto the parking lot pavement. - Hydraulic hoses on equipment were leaking and needed a drip pan to capture any leaks and a schedule for repair. If compliance corrective actions were identified,what timeline for correction/follow-up was provided? No timeline was noted during the inspection Notes/Comments/Recommendations A site specific SWPPP should be kept on site and should be available on request. If the SWPPP is digital,shop personnel should be able to readily access that document without assistance and should be familiar with all aspects of that document.All inspections required by the MS4 permit should be provided to the Maintenance shop supervisor as well as the public works director for their review and any corrective actions such as missing drain plugs,cover lids, leaks and cleanup.Any corrective actions should be documented in the SWPPP with a schedule for completion. The inspector walked the entire parameter of the site and viewed all the outside areas.All areas of the municipality should be included in the M54 inspection.This includes areas inside buildings to ensure there are no improperly stored chemicals or chemical leaks that can reach the stormwater. Inspect under the equipment shed to ensure that no equipment is leaking and need maintenance and that no containers are leaking or improperly stored. Inside the maintenance shop should be inspected to be sure there are no spills on the floor that can be tracked outside and there are no leaks that have not been properly cleaned up or repaired. Inside the dumpster containment area should be included in this inspection to ensure the dumpsters are properly closed and the drain hole is plugged and that no excess trash is stored around dumpsters NCS000460 Knightdale MS4 Audit 20190823 Page 19 of 23 Site Visit Evaluation: MS4 Outfall No. 1 Outfall ID Number: Date and Time of Site Visit: OTLT-0204 8/23/2023 3:05 pm—3:45 pm Outfall Location: Outfall Description(Pipe Material/Diameter,Culvert,etc.): 104 Indian Spring Drive 36-inch RCP Receiving Water: Is Flow Present?If So,Describe(Color,Approximate Flow Rate, Mingo Creek Sheen,Odor,Floatables/Debris,etc.): Most Recent Outfall Inspection/Screening(Date): No active flow. 4/4/2023 Days Since Last Rainfall: Inches: 24 hours 0.10inches Name of MS4 Inspector(s)evaluated: Dylan Kirk Observations Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? North Carolina State University Stormwater SCM Inspection&Maintenance Certification Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations? Yes. Inspection Procedures Does the inspector's process include the use of a checklist or other standardized form? Yes. Does the inspector's process include taking photos? Yes. Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues?If so,what were they? No. NC5000460 Knightdale MS4 Audit_20190823 Page 20 of 23 Site Visit Evaluation: MS4 Outfall No. 1 Inspection Results Did the outfall inspection result in any work orders or maintenance requests?If so,for what issue(s)? No. Will a follow-up outfall inspection be conducted?If so,for what reason? No. Notes/Comments/Recommendations All site information was recorded in a digital inspection report form and the material,measurements,and condition of the outfall was all assessed. Inspector's observations/notes: - Slight undermining of the pipe. - Slight cracking above the pipe. - Brush growing on top of the pipe. - Slight joint separation—need to monitor changes during future inspections. - Exposed geotextile and tarp material/ - Slight erosion in the channel banks,but overall stable. We recommended that any repair areas or preventative maintenance requirements be documented(ex.Cutting trees that are growing on or around the outfall)These issues should be documented regardless of whether there is time and manpower for the task. Documenting outlet conditions should be required for outlet condition awareness and categorization for future improvements and repairs. NCS000460 Knightdale MS4 Audit-20190823 Page 21 of 23 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Site Name: Date and Time of Site Visit: Public Works Facility SCM 8/23/2023 2:15 pm—2:55 pm Site Address: SCM Type: 1102 Great Falls Court Wet detention basin Knightdale, NC 27545 Most Recent MS4 Inspection(Include Date and Entity): 6/16/2023 Name of M54 Inspector(s)evaluated: Most Recent MS4 Enforcement Activity(Include Date): Dylan Kirk N/A Name(s)and Titles)of Site Representative(s)Present During the Site Visit: !Name Title Dylan Kirk Town of Knightdale,Stormwater Technician Ike Archer Town of Knightdale,Stormwater Manager Observations Site Documentation Does the site have an operation and maintenance plan? Currently,there is a general operations and maintenance agreement that applies to all SCM's. However,SCM's need site specific Operation and Maintenance plans to take into account specific plantings,vegetation and conditions depending on what type of SCM is being inspected Does the site have records of annual inspections?Are they performed by a qualified individual? Yes.There is one annual inspection by an engineer and monthly inspections by the subcontractor with addition MS4 inspections by the Town of Knightdale. Inspector Training/Knowledge What type of stormwater training does the MS4 inspector receive?How often? North Carolina State University Stormwater SCM Inspection&Maintenance Certification Did the MS4 inspector appear knowledgeable about MS4 requirements for post-construction site runoff controls? Yes. Did the M54 inspector appear knowledgeable about post-construction BMPS(general purpose/function,components,O&M requirements,etc.)? Yes. Inspection Procedures Does the M54 inspector's process include the use of a checklist or other standardized form?What format? Yes. Does the MS4 inspector's process include taking photos? Yes. NCS000460_,Knightdale MS4 Audit_20190823 Page 22 of 23 Site Visit Evaluation: Post-Construction Stormwater Control Measure No. 1 Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections? Yes. Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge? Yes. Did the MS4 inspector miss any obvious operation and maintenance deficiencies?If so,explain: No. Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing? Yes. Compliance/Enforcement What,if any,enforcement actions(verbal warnings, NOV, etc.)did the inspection result in? None. If compliance issues were identified,what timeline for correction/follow-up was provided? None for this inspection.Only routine maintenance and ground cover improvements were noted for corrective actions. Notes/Comments/Recommendations Provide maintenance schedules for any SCM's with newly discovered and ongoing issues NCS000460_Knightdale MS4 Audit_20190823 Page 23 of 23 a .